Wakely Analysis Signals Significant Enrollment Shifts in ACA Individual Market as 2026 Unfolds

OKEMOS, Mich., April 15, 2026 /PRNewswire/ -- Wakely Consulting Group, an HMA Company, today released a new analysis of the Affordable Care Act (ACA) individual market that points to meaningful changes in enrollment, consumer behavior, and overall market morbidity as 2026 progresses. Drawing on data representing approximately 80% of the market, the findings highlight early indicators that could shape pricing, participation, and policy impacts heading into 2027.

The analysis finds that while initial plan selection data¹ suggested only modest declines in enrollment, a deeper look at premium payment behavior tells a more complex story. On average, only 86% of enrollees paid their first premiums in January 2026, with significant variation across states.

"This is a moment of transition for the individual market from recent years," said Michelle Anderson, a Wakely actuary and coauthor of the report. "What we are seeing is not just a change in enrollment levels, but a shift in the profile of members who remain covered, the types of plans they choose, and the overall risk profile of the market."

Key Findings

• Enrollment declines may be more substantial than early data suggests.
  While plan selections declined by roughly 5%, actual enrollment is projected to fall between 17% and 26% on average when accounting for unpaid premiums and ongoing attrition. Some states may see reductions higher than 26%, with higher reductions skewing toward states operating under a Federally Facilitated Exchange.
  
  
• Premium payment behavior is a critical indicator of market stability.
  States with higher premium increases and higher rates of automatic reenrollment tended to have lower payment rates, signaling more potential coverage losses as the year progresses.
  
  
• Consumers are shifting to lower-cost coverage options with less generous benefits.
  Enrollment in Bronze plans increased significantly, while Silver plan participation declined. Gold plan enrollment also increased in many states where Silver is more expensive than Gold coverage, driven by low-income members, who are eligible for cost-share reduction Silver plans, buying "down" to save on premiums. These changes suggest that affordability pressures are driving consumers to accept higher potential out-of-pocket costs in exchange for lower premiums.
  
  
• The risk pool is expected to worsen.
  The analysis estimates that morbidity could increase between 2.9% and 6.5% in 2026, as healthier individuals are more likely to exit the market.
  
  
• State-level variation is pronounced.
  State-based exchanges generally retained more enrollees and experienced less disruption than Federally Facilitated Exchanges, underscoring the importance of local policy and program design. Even within state cohorts, significant variation is evident.

"These findings highlight a level of uncertainty that issuers and policymakers will need to carefully navigate," said Michael Cohen, coauthor of the report. "Changes in enrollment, plan selection, and member health status will directly influence premium rate development and market participation in 2027."

Implications for the Market
The expiration of enhanced premium tax credits, combined with rising healthcare costs and policy changes affecting eligibility, has created a more volatile environment. The analysis suggests stakeholders will need to closely monitor emerging data throughout 2026 to understand how these trends evolve and to make informed decisions about pricing, participation, and policy strategy.

"Looking ahead, the key question is not just how much the market will shrink, but how its composition will change," Chia Yi Chin, coauthor, added. "Our findings are based on early, emerging data. We are committed to continuing to provide insights to stakeholders through our work in the coming months."

About the Analysis
The study is based on a proprietary dataset collected from more than 75 carriers across over 30 markets, representing a substantial share of ACA-compliant enrollment. It examines premium payment patterns, enrollment dynamics, and risk trends to provide an early view of market conditions in 2026.

About Wakely Consulting Group, an HMA Company
Founded in 1999, Wakely Consulting Group, an HMA Company, is well known for its top-tier healthcare actuarial consulting services. With nine locations nationwide, Wakely boasts deep expertise in Medicare Advantage, Medicaid managed care, risk adjustment and rate setting, market analyses, forecasting, and strategy development. The firm's actuaries bring extensive experience across all sectors of the healthcare industry, collaborating with payers, providers, and government agencies.

¹ Centers for Medicare & Medicaid Services. Health Insurance Exchanges 2026 Open Enrollment Report. Available at: https://www.cms.gov/files/document/health-insurance-exchanges-2026-open-enrollment-report.pdf.

SOURCE Wakely Consulting Group